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Sec.2: Hazard Management and Safety Case (Consultancy Services) [Table of Contents] App.A: Summary of Key UK Safety Compliance Milestones

DNV-OSS-202 Verification for Compliance with UK Shelf Regulations

[-] Sec.3: Written Schemes (Verification Services)

SECTION 3
Written Schemes (Verification Services)

Sec.3
A. Introduction

Sec.3
A 100   General

Sec.3 A
101   This section describes the UK requirements for written scheme of verification/examination required by SCR.

The written scheme are for verification that important plant and equipment is suitable to keep risks as low as reasonably practicable, throughout the unit/installation operation in UK waters.

Sec.3
B. Requirements for Verification

Sec.3
B 100   General

Sec.3 B
101   The objective of the written scheme is to verify that the safety critical systems and equipment are, and remain, suitable to keep prevent, detect, control and mitigate the risks.

Sec.3 B
102   The requirements are briefly discussed in B200 and B300. DNV verification services for the Written Scheme are given in C.

Sec.3
B 200   Verification of safety-critical elements

Sec.3 B
201   SCR regulation 15 requires that a record of safety-critical elements be established. The record of safety-critical elements shall be subject to comment by an independent competent person, and any comments or reservations noted.

Sec.3 B
202   The safety-critical elements are subject to a verification scheme which is a written scheme drawn up by, or in consultation with, an independent competent person. Verification activities under the scheme shall be performed by an independent and competent person, although he may take credit for other work. (See Sec.3 C401).

Sec.3 B
203   The verification scheme applies to the specification, design, construction, installation, operation and condition of safety-critical elements.

For fixed installations, and installations at a fixed location, a verification scheme shall be available before completion of final design, and shall be operated and maintained throughout the installation life.

For mobile units with intent to operate in UK waters, a verification scheme shall be in place prior to entry to UK waters.



Sec.3 B
204   The scheme must be kept under review and revised as necessary to ensure the suitability of safety-critical elements.

Sec.3
B 300   Examination of PFEER plant

Sec.3 B
301   PFEER Regulation 19 requires that plant for detection, control and mitigation of fires and explosions, for escape and evacuation, and for certain emergency alarms and communications, be subject to a Written Scheme of Examination to be performed by an independent, competent person. Examination should include checking against performance standards identified from the PFEER assessment.

Sec.3
B 400   Examination of personal protective equipment

Sec.3 B
401   PFEER Reg 18 requires a written scheme for examination and, where required, testing, of personal protective equipment (PPE) to be performed by competent person. PPE includes equipment which protects persons against the effects of fire, heat, smoke, fumes, toxic gas, or immersion in the sea.

Sec.3
C. Verification Services

Sec.3
C 100   Appointment as ICP

Sec.3 C
101   UK regulations SCR and PFEER require comment and verification by a demonstrably independent and competent person(s). As an entirely independent foundation, working with all technical aspects of offshore safety, DNV can provide suitably independent and competent personnel to meet UK verification requirements at all stages of the installation lifecycle.

Sec.3 C
102   This includes:
—comment on record of safety critical elements
—preparation and consultation for SCR and PFEER written schemes
—performing and reporting SCR and PFEER written schemes activities
—review and revision of SCR verification scheme through phases such as design and construction, in-service, modification.

Sec.3
C 200   Review of the List of SCEs

Sec.3 C
201   The owner should produce a list of SCEs which the ICP will review and agree. This review is to ensure that the items needing to be in the scheme are, in fact, present.

Sec.3
C 300   Verification scheme - development and review

Sec.3 C
301   The scheme will document all the requirements to be addressed. The written scheme will address both the SCR verification of safety-critical elements, as well as the PFEER verification.

Sec.3 C
302   The scheme will contain all activities and information as necessary to enable the ICP to verify the initial and ongoing suitability of the safety-critical elements and other plant.

Sec.3 C
303   DNV will prepare a scheme to include, at minimum:
—list of SCE and PFEER measures
—type and frequency of activities under the scheme, including reference to activities credited under class and duty holder's own schemes
—findings from activities under the scheme
—remedial action recommended based on findings under the scheme
—remedial action performed in connection with the scheme
—reporting lines between ICP and duty holder
—arrangements for revision and review of scheme.

Other aspects, such as interface of the scheme with management of major accidents, can be included as agreed.

Activities under the scheme will be an appropriate selection of:
—examination, testing and test witnessing
—documentation review, e.g. design, specification, certificate, CE marking or other standards applied
—visual examination of ongoing suitability of equipment, through inspection, maintenance
—assessment of any relevant quality and management systems
—assessment and credit for work performed under classification or duty holder's own scheme.

These activities shall be performed at suitable times and intervals to ensure that the equipment continues to meet the performance requirements.

Sec.3
C 400   Initial suitability

Sec.3 C
401   Before the SCE is presented for verification the Duty Holder is to ensure that it meets the performance standard. He can do this in consultation with the OEM and any other relevant parties, as part of his own assurance process. Once he is satisfied it is ready the ICP will carry out the initial suitability work scope in accordance with specifically generated Design Performance Standards. The scope normally requires a documentation review and approval by the ICP as well as inspection and testing of the SCE during the design, construction and commissioning phases.

Sec.3 C
402   In the case of an existing SCE where a new PS is set, a similar process of document review and testing would be carried out.

Sec.3
C 500   Ongoing suitability

Sec.3 C
501   During operation of the scheme, DNV can act as the ICP and carry out the examination activities described in the WSE. Examination means careful and critical scrutiny of plant, in or out of service as appropriate, using suitable techniques, including testing where appropriate:
  1. to assess its suitability for the purpose for which it is used or provided;
  2. to assess its actual condition; and
  3. to determine any remedial measures that should be taken.

This examination will be one or all of inspect, test, review or audit of the equipment and systems.

DNV as ICP will record:
—what has been done
—findings of activities under the scheme
—remedial action recommended
—remedial action performed
—ICP reservations.

Note that temporary equipment which is, or affects, a safety-critical element will also be subject to verification for initial suitability, safe placement and hook-up, and continuing suitability (as necessary).

Sec.3 C
502   DNV will report any findings to the duty holder, who is then required to ensure that the findings are notified and addressed at an appropriate level of management. If the duty holder wishes, these matters can be closed out by DNV when suitably addressed and resolved with the duty holder.

Sec.3
C 600   Scheme revision and review

Sec.3 C
601   Where required under SCR, DNV will review and revise the effectiveness of the scheme throughout operation. Reviews will address:
—the record of SCE and performance standards is valid and suitable
—the written scheme is effective in verifying and maintaining the SCE and performance standards.

Modifications or additions to activities under the scheme will be made where appropriate.

Sec.3 C
602   Further information regarding practical interpretation and implementation of the regulations can be obtained from DNV on request.

Sec.3
C 700   Performance assurance

Sec.3 C
701   Other activities intended to ensure the safety and operability of a unit or installation can be reviewed and credited in a written scheme wherever appropriate. These can include:
—duty holder's own "performance assurance" such as planned maintenance, safety tests and exercises etc.
—classification
—other 3rd party certification and verification type activities.

Sec.3
D. Application for Classed Units

Sec.3
D 100   General

Sec.3 D
101   Work under UK written scheme requirements and classification can be combined wherever possible to:
—take advantage of the experienced systematics and resources of DNV classification
—improve cost efficiency through avoiding unnecessary duplication of work.


Sec.3 D
102   The HSE have accepted that work carried out under the scope of Class/Flag can be considered as contributing to fulfilling the requirements of the Verification Scheme. They accept that there is no need for double survey of the same items under different headings.

Sec.3
D 200   Application to installations

All installations

Sec.3 D
201   DNV offshore classification includes independent design and construction approval, and ongoing approval through survey, of important safety features of installations. Where appropriate, this can be directly credited into the UK scheme. This can be particularly useful in consideration of the following:

Conversions to floating production installations (Fixed Installations)

Sec.3 D
202   Floating Production Installations are fixed installations under UK regulations, and written scheme must address original design and construction, as well as modifications, such as offshore production systems. DNV classification can be useful for some of this retrospective verification.

Sec.3 D
203   Design and construction verification of topsides can take credit for additional DNV class notations, such as PROD and DRILL.

Mobile Units

Sec.3 D
204   Written schemes must be in place when a mobile unit enters UK waters. These schemes must include demonstration of adequate design and construction, as well as ongoing operations.

Sec.3 D
205   Similar to floating production installations above, classification can be useful for some of this retrospective design and construction verification under classification. Further design and construction verification will only be required where not originally identified or suitable under classification, or where systems require modification for use in the UK.

Sec.3 D
206   UK regulations therefore recommend that mobile offshore units are designed and built with verification requirements in mind. These will simplify acceptance for operation in UK waters, and avoid the need for major remedial action by duty holder.

Sec.3
D 300   Class notation

Sec.3 D
301   Classed units/installations for which DNV provides verification services for establishing and performing a UK written scheme including all safety-critical elements may be assigned a class notation

UKVS

Details of the verification services shall be stated in the appendix to the class certificate.

Sec.2: Hazard Management and Safety Case (Consultancy Services) [Table of Contents] App.A: Summary of Key UK Safety Compliance Milestones